L'Etoile v. NE Finish Systems, Inc.

2008 DNH 168
CourtDistrict Court, D. New Hampshire
DecidedSeptember 10, 2008
DocketCV-06-390-JL
StatusPublished

This text of 2008 DNH 168 (L'Etoile v. NE Finish Systems, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
L'Etoile v. NE Finish Systems, Inc., 2008 DNH 168 (D.N.H. 2008).

Opinion

L'Etoile v. NE Finish Systems, Inc. CV-06-390-JL 9/10/08 P UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Nicole L'Etoile

v. Civil No. 06-CV-390-JL Opinion No. 2008 DNH 168 New England Finish Systems, Inc.

O R D E R

The plaintiff, Nicole L. L'Etoile, has sued her former

employer. New England Finish Systems, Inc. ("New England Finish")

for discrimination, including a hostile work environment, and

retaliatory discharge in violation of Title VII of the Civil

Rights Act of 1964, 42 U.S.C. §§ 2000e-2(a)(1), 2000-e-3(a).

L'Etoile worked as a taper for the company, a drywall contractor,

from early 2002 until her termination in the spring of 2004.

This court has jurisdiction under 28 U.S.C. § 1331 (federal

question). Each side has filed a number of motions in limine

seeking to exclude certain evidence from the upcoming trial. The

court heard argument on these motions at the final pre-trial

conference in this matter on September 4, 2008. Based on those

arguments, as well as those set forth in the parties' filings,

the court makes the following rulings on the motions in limine. I. L'Etoile's motion to exclude the finding of "No Probable Cause" by the New Hampshire Human Rights Commission

Prior to L'Etoile's commencement of this action, she had

filed a charge of discrimination against New England Finish with

the New Hampshire Human Rights Commission ("NHHRC"), alleging,

inter alia, the same unlawful conduct. Following an

investigation, the NHHRC found that there was no probable cause

for the charge. That finding, unaccompanied by any explanation,

analysis, or subsidiary findings, was announced in a letter to

the parties' counsel. The Equal Employment Opportunity

Commission ("EEOC") subsequently adopted the NHHRC's finding,

again, without any accompanying explanation. L'Etoile moves to

exclude any evidence of the NHHRC's or the EEOC's finding under

Rule 403 of the Federal Rules of Evidence.1

1 New England Finish argues that, under the prevailing law, such "findings should be admitted when they are deemed to be trustworthy." It is true that the Federal Rules of Evidence recognize an exception to the hearsay rule, in civil actions, for "factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate lack of trustworthiness." Fed. R. Evid. 803(8)(C). But the "trustworthiness" of agency findings resolves only the hearsay problem; it does not also mean that they are admissible notwithstanding Rule 403. See, e.g., Paolitto v. John Brown E.&C., Inc., 151 F.3d 60, 64-65 (2d Cir. 1998) (noting that, with reference to EEOC reports under Rule 803(8)(C), "the fact that evidence is within an exception to the hearsay rule does not by itself make it admissible per se").

2 Relevant "evidence may be excluded if its probative value is

substantially outweighed by the danger of unfair prejudice,

confusion of the issues, or misleading the jury, or by

considerations of undue delay, waste of time, or needless

presentation of cumulative evidence." Fed. R. Evid. 403. The

First Circuit has upheld the use of this rule to exclude a

finding of "reasonable grounds to believe that unlawful

discrimination has occurred" by the Maine Human Rights Commission

from the ensuing trial of the discrimination claim because "such

an agency determination, unaccompanied by relevant facts, tends

to be more prejudicial than probative." Patten v. Wal-Mart

Stores E ., Inc., 300 F.3d 21, 26-27 (1st Cir. 2002) .

This court agrees with that approach here. Neither the

NHHRC's nor the EEOC's "finding" of no probable cause for

L'Etoile's complaint offers any explanation of why or how the

agency reached that conclusion, giving the findings little

probative value. New England Finish responds that the findings

likewise carry little risk of unfair prejudice, but, assuming

that is true, other criteria under Rule 403--"considerations of

undue delay, waste of time, or needless presentation of

cumulative evidence"--weigh heavily against admitting them.

That much is clear from the briefing on the motion in limine,

which consists largely of L'Etoile's attacks on, and New England

3 Finish's defense of, the methods of the NHRRC's investigator.

Allowing this battle to play out at trial would expend

significant resources for little benefit. As the court of

appeals observed in Patten, the conclusory findings have little

probative force anyway, and would distract the jury from its

ultimate task, which is to decide whether the alleged acts of

discrimination and retaliation in fact occurred, not whether the

NHHRC correctly decided that they likely did not.

A number of courts have relied on similar concerns in

excluding, or upholding the exclusion of, agency resolutions of

employment discrimination charges, i.e., the "likelihood that

the trial will deteriorate into a protracted and unproductive

struggle over how the evidence admitted at trial compared to the

evidence considered by the agency." Paolitto, 151 F.3d at 65;

see also, e.g., Coleman v. Home Depot, Inc., 306 F.3d 1333, 1347

(3d Cir. 2002); Hall v. W. Prod. Co., 988 F.2d 1050, 1058 (9th

Cir. 1993); Tulloss v. Near N. Montessori Sch., Inc., 776 F.2d

150, 153-54 (7th Cir. 1985); Johnson v. Yellow Freight Svs.,

Inc., 734 F.2d 1304, 1309-10 (8th Cir. 1984); Cook v. Hatch

Assocs., No. 02-065A, 2007 WL 1267023, at *2-*3 (W.D.N.Y. Apr.

30, 2007). In line with these and other like decisions, the

4 court grants L'Etoile's motion to exclude evidence of the

findings of no probable cause by the NHHRC and EEOC.2

II. The parties' motions to exclude events not involving L'Etoile's employment at New England Finish

L'Etoile seeks to prevent New England Finish from

presenting evidence that no other woman besides her has

complained about sex discrimination at the company and that,

since she left, another woman has worked there without incident.

New England Finish, in turn, seeks to prevent L'Etoile from

presenting evidence that women who worked at the company before

her also experienced sex discrimination. Each side

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